> "There are no FCC *emission requirements* for equipment used in
> appliances."
You're confusing emissions with the certification requirement. Under Part
15.103(d), appliances are exempt from the certification requirement.
Appliances are not exempt from the generation of harmful emissions as an
unintentional radiator. Generally, if an appliance is causing harmful
interference to the user of a licensed service, the fact that the
manufacturer was not compelled to certify the appliance in no way grants
special dispensation to the device's owner if that device produces harmful
interference. When put on notice, the owner of the device must still
protect a licensed service and cease device operations until the
interference is cured.
I have been advocating a change to this rule for the past several years.
Frankly, the time is ripe for a Petition for Rulemaking. I'm just not sure
if the ARRL wants to take that on at the moment and the petition really
needs a strong sponsor like the League for what it will definitely face.
There will be significant opposition from appliance manufacturers and
manufacturers of appliance sub-components like those that manufacture
direct-drive, variable-speed motors and switch-mode power supplies. An
oddity of the current rules implies, for example, that a SMPS that may
require Part 15(B - residential) certification as a stand-alone device but
is protected from the certification requirement when it's embedded into an
appliance.
What clearly does not make sense is the continuation down the current road
where the FCC's enforcement branch must become engaged in conflict
resolution between a licensee and the owner of the interference-generating
appliance. With certification of appliances that contain any switch-mode
technology or microprocessors, the FCC's enforcement job potentially gets a
whole lot easier and that, among other key points, would become pivotal in a
Petition for Rulemaking.
Paul, W9AC
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